My Lords, I do not see the need for any requirement for impact assessments in the Bill, because the need does not arise. As my noble friend Lord Forsyth has said, the Bill is not taking us out of the EU but simply enabling the Government to trigger Article 50. There is no impact to assess from that enabling. This is not the place to get into detail over the negotiations or the structures around them, and it is vital that we do not bind the Government, either administratively or legally, in their negotiations, because that will only undermine their ability to get the best possible deal for the country.
I appreciate that the noble Lord, Lord Hannay, said that my noble friend Lord Blencathra was being cynical about impact assessments, but I dealt with a number of impact assessments when I worked in government and was frequently frustrated by their lack of accuracy. This was in part due to the lack of management information in government departments. Non-executive directors of government departments appointed from outside the Civil Service were often shocked by the poor quality of the information on which decisions were based. My noble friend Lord Maude, who I see in his place, made valiant attempts to improve the quality but I fear there is still a long way to go. Just last week, my right honourable friend Sir Oliver Letwin criticised the quality of advice from civil servants, in particular expressing the concern that not enough of their advice was factually based. My concern is therefore a general one about the utility of such impact assessments.
The other point I was going to make, which I think has already been made, is that impact assessments are inherently driven by a number of assumptions and predictions. I do not want to labour the issue, but various predictions made about the immediate consequences of Brexit—not only by Her Majesty’s
Treasury but also by the IMF, the IFS, the OECD and the Governor of the Bank of England—failed to materialise. My concern is that impact assessments could well be of dubious quality and accuracy. On that basis, I urge noble Lords not to press their amendments.